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TMI Blog2023 (8) TMI 1195X X X X Extracts X X X X X X X X Extracts X X X X ..... ata Rawat, Advocates. For the Respondent Through: None. RAJIV SHAKDHER, J. (ORAL): CM No.39036/2023 1. Allowed, subject to just exceptions. CM No. 39035/2023 [Application filed on behalf of the appellant/revenue seeking condonation of delay of 14 days in filing the appeal] 2. This is an application moved on behalf of the appellant/revenue, seeking condonation of delay in filing the appe ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... assed by the Tribunal. 8. These appeals are ITA No. 322/2023, ITA No. 323/2023 & ITA No. 327/2023. 9. We notice that it is not in dispute that the assessment in the abovecaptioned AY also stood completed. 10. The Tribunal has returned the finding of fact that no incriminating material was found, insofar as the AY in issue, i.e., AY 2009-10, was concerned, apart from AY 007-08 and 2008-09. 11. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... o the document found during the search. xxxx xxxx xxxx 23. In the present case, the alleged documents were seized during the search are not pertaining to the assessment year 2007-08 to 2009-10 and the same is belongs to Assessment years 2010-11 & 2011-12, therefore, the addition made by the A.O. for the years under consideration i.e. 2007-08 to 2009-10 cannot be sustained by applying the rat ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Online SC 481.
14. Given the position that no incriminating material was found qua the AYs in issue, we find no reason to interfere with the impugned judgment.
15. Therefore, according to us, no substantial question of law arises for our consideration.
16. The appeal is accordingly closed.
17. Parties will act based on the digitally signed copy of the order. X X X X Extracts X X X X X X X X Extracts X X X X
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